Assess whether notices match the actual decisioning reasons (7083aa)

SITUATION A live Fair Lending CRA and Special-Purpose Programs file in a manufactured-housing lender with dealer-originated files now turns on model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class. Exam-response coordinator should state what that extract proves for whether notices match the actual decisioning reasons.

DECISION Exam-response coordinator in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after a SPCP that originated almost no loans to the intended class. 2. Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after a SPCP that originated almost no loans to the intended class for exam-response coordinator. 3. Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after a SPCP that originated almost no loans to the intended class. 4. Refuse a Fair Lending close: exam-response coordinator does not have the decision notices match the actual turns on in model-reason-code mapping that does not match notices.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 2. Check HMDA coding and underwriting policy against notices match the actual. 3. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 4. For this Fair Lending CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices against a SPCP that originated almost no loans to the intended class and write the one fact that would move notices match the actual for exam-response coordinator.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class). The follow-on CRA and Special-Purpose Programs action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.